How CAP advocacy protected Medicare pay for pathologists

The 2026 Medicare Physician Fee Schedule was a mix of good and bad news for pathologists.

The impact: We reviewed adverse provisions, mainly the "efficiency adjustment," that will negatively affect pathology and laboratory pay in 2026.

• We are vigorously pushing back against these unjust and ill-conceived policies.

At the same time, we identified three pieces of good news in the fee schedule— which are the result of CAP advocacy.

• Our advocacy wins show that engaging with CMS and Congress can lead to positive change.

Pathologists' pay

The Centers for Medicare & Medicaid Services (CMS) says it will not use data from the American Medical Association’s Physician Practice Information Survey in its payment rate calculations.

• The CAP had strongly urged the CMS to set aside the survey due to serious concerns about sample sizes and statistical uncertainty.
• By CMS not implementing the survey data, pathologists will avoid an estimated 8% reduction in reimbursement.

Protecting the value of pathology services

The CAP has advocated fiercely for consistency in the application of the efficiency adjustment.

• We argued for the CMS to correctly classify pathology clinical consultations as time-based services and exempt them from the adjustment.
• The work relative value units (RVUs) for CPT codes 80503, 80504, 80505, and 80506 will remain unchanged and will not decrease by 2.5% in 2026.

As noted, the CAP is still strongly opposed to the overall finalization of the efficiency adjustment and is calling for congressional action to reverse payment cuts to our services.

Safeguarding the field of pathology

When the CMS finalized a policy to reduce facility practice expense RVUs, it acknowledged that services billed with the 26-modifier will be exempt from the site of service payment differential.

• As a result, the RVUs for most pathology services performed in the facility setting will not face a significant reduction.
• This important exemption follows extensive advocacy by the CAP, which urged the CMS to recognize that the proposed differential would have disproportionately affected pathologists and negatively affected patient care.

The CAP will continue to advocate against reductions to facility practice expense RVUs for pathology services that are not billed with the 26-modifier, including bone marrow, blood, and apheresis services. CAP members can also urge Congress to stop the Medicare payment cuts.

Go deeper: The CAP will review the final rule in a webinar at 3:00 PM ET on Friday, December 5. Register today!